North American Commission Report Reveals Fate of 5B kg Industrial Pollutants

Montreal — The North American Commission for Environmental Cooperation (CEC) today released a new report compiling and analyzing data reported by approximately 24,000 industrial facilities in Canada, Mexico and the United States to their respective national pollutant release and transfer registers. The report reveals important gaps in the reporting and tracking of transfers to disposal across the region due to differing reporting requirements, shared responsibilities across agencies and jurisdictions, and the lack of information about the fate of waste pollutants when they are transferred to third parties (such as waste management service providers) or across national borders. The report also provides insights about the challenges facing facilities relative to implementing pollution prevention and sustainable production practices and offers examples of alternatives to the generation and disposal of industrial waste.

Since 1995, the CEC has worked with governments, industry, civil society and academia through the North American Pollutant Release and Transfer Register (PRTR) Initiative to promote and enhance access to comparable and complete PRTR data for the region to support decisions about pollution prevention and sustainability. In parallel with the release of the 16^th edition of Taking Stock, the CEC has launched the enhanced Taking Stock Online web portal featuring a searchable database and tools that allow researchers, decision-makers and the general public to explore the latest integrated North American PRTR data.

"In the spirit of the public's right-to-know, Taking Stock presents and analyzes data on industrial pollutant releases and transfers to inform decisions about preventing pollution and advancing environmental justice by reducing the risk of exposure to contaminants of vulnerable communities," said Jorge Daniel Taillant, CEC Executive Director.

"This report sheds light on important data gaps across North America that stem from differing national reporting requirements and from the transfer of responsibility for waste pollutants after they leave the source facility. These gaps in information about the quantities and management of substances can, for example, constrain our ability to respond to extreme events and disasters, such as floods, that risk re-mobilizing pollutants from disposal sites and contaminated soils. In the context of climate change, we must re-evaluate the 'business as usual' approach to the use of pollutants and the generation of hazardous waste."

Key findings:

• Almost 24,000 industrial facilities across North America reported more than 5 billion kilograms (kg) in pollutant releases and transfers each year. The distribution among release and transfer types is roughly as follows (average of 5 years):

Release or Transfer Category % of total

On-Site Air Emissions: 7.00

On-Site Surface Water Discharges: 4.00

On-Site Underground Injection: 5.00

On-Site Disposal or Land Releases: 41.00

Off-site Transfers to Recycling: 26.00

Off-site Transfers to Treatment, sewage, energy recovery: 10.00

Off-site Transfers to Disposal: 6.00

• Together, about fifteen industry sectors accounted for 80% of the reported annual totals – including metal ore mining, iron and steel mills/ferroalloy manufacturing, basic chemicals manufacturing, oil and gas extraction, and waste management. Similarly, of the more than 500 pollutants reported, approximately 20 accounted for 88% of annual releases and transfers. Just five of them—zinc, manganese, lead, and copper compounds, along with nitric acid/nitrate compounds—together accounted for about 45% of the total.
• The report's special analysis of off-site transfers to disposal reveals that approximately 11,000 facilities, many of them in these same top sectors, reported transferring about 335 million kg of their waste pollutants to disposal (representing 6% of total annual releases and transfers). The top pollutants – metal compounds such as zinc, manganese, lead and barium, along with hydrogen sulfide – accounted for about 55% of the total.
• The report provides examples of the health and environmental issues associated with common industrial disposal practices such as landfills or surface impoundments, underground injection, land application, and "other" disposal. It also reveals important gaps in the data that result from differences among PRTR reporting requirements across the region, as well as the shared responsibility for the reporting and management of hazardous waste. These gaps impede our ability to track pollutant transfers from their source to their ultimate disposition, particularly when they involve third-party contractors or when waste pollutants cross national borders.
• A key objective of the CEC's North American PRTR Initiative is to support pollution prevention and sustainability within industry. This edition of Taking Stock provides information and examples of alternatives to the generation and disposal of industrial waste and shows how PRTRs can serve as important tools to support the transition from a linear to a circular economy, for instance, by calling for detailed reporting of facilities' pollution prevention efforts, needs and challenges that can yield insights for industry and governments.

About the North American Pollutant Release and Transfer Register Initiative

The CEC's North American Pollutant Release and Transfer Register (NAPRTR) Initiative promotes public access to data and information reported by industrial facilities in North America to improve understanding of the sources and management of pollutants of concern across the region and support decisions relative to pollution prevention and sustainability.

Since 1996, the NAPRTR Initiative has been a cornerstone of the CEC's work on pollutants and environmental health. Efforts are focused on adding value to national PRTR data through their integration, analysis and dissemination via the Taking Stock report series and the Taking Stock Online website featuring a searchable database and tools. Data are reported by industrial facilities to the three national PRTRs in North America: Canada's National Pollutant Release Inventory; Mexico's Registro de Emisiones y Transferencia de Contaminantes; and the United States' Toxics Release Inventory.

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TAKING STOCK VOL. 16 - OVERVIEW/KEY FINDINGS

• 16^th edition of Taking Stock report (first analysis was in 1997: using 1994 data from Canada and US)
  • Feature analysis of Off-site Transfers to Disposal: data in TS Online now available by modality of off-site waste disposal (i.e., data are disaggregated into 6 off-site disposal categories)
• Taking Stock Online: data available for 2006-2020 (2019 and 2020 data added as of 2 May report launch), compiled from the three national Pollutant Release and Transfer Registers (PRTRs)
  • Landing Page: enhanced to provide more context, graphics with key data elements
  • Cross Border Transfers: can be searched by source and recipient facility
  • GHG Data: to be added this year (will include facility-level data for a core set of common GHGs available from Mexico's RETC, Canada and US GHG Reporting Programs).

Taking Stock vol. 16: Feature Analysis of Off-site Transfers to Disposal

Goal: Enhance our understanding of North American industrial waste disposal practices, potential impacts, and alternatives to the generation and disposal of industrial waste.

Key Findings:

• About 45,000 facilities across NA have reported to the PRTRs over the 2006-2020 period
• For 2014-2018 (the period of analysis in this report, with 2018 being the latest trinational data available at the time of writing), about 11,000 of the total 24,000 facilities reporting Total Rs and Ts during this period reported close to 335 million kg to Off-site Disposal (OSD) each year
• Reported Off-site disposal categories (rough % of total, 2014-18):
  • Transfers to landfill/surface impoundment: close to 50% (15% decline from 2014-18)
  • Underground injection: about 20%
  • Transfers to stabilization prior to disposal: 12% (30% increase over 5 years)
  • "Other" disposal (unknown): about 10%
  • Land application: 5% (40% increase over 5 years)
  • Storage prior to disposal: 4%
• Canada & US: OSD represents about 6% of total releases and transfers (TRT) each year.
  • In Mexico, OSD increased from 12% of TRT in 2014 to 34% in 2018 (driven by gold and silver ore mining).
• Approx. 10 industry sectors and 10 pollutants/pollutant groups = 2/3 of total OSD each year:
  • Top sectors: Iron and steel mills/ferroalloy manufacturing, Oil and gas extraction; Electric utilities; Waste management facilities
  • Top Pollutants: Zinc, Manganese, Lead and Barium compounds, Hydrogen Sulfide, Methanol.

• The report enhances our understanding of industrial disposal practices and risks and sheds light on information gaps that can impede the ability to track pollutants sent to disposal, as well as to assess and respond to extreme events (e.g., floods), that risk re-mobilizing pollutants from disposal sites and contaminated soils
• Currently, it is difficult to track pollutants from their sources to their final destination, due to:
  • The transfer of responsibility for the waste to third parties, such as waste management facilities, which makes it difficult to track the pollutants once they leave the source facility.
  • Pollutants crossing national borders (where regulations and reporting requirements can differ)
  • Source facility's incomplete or inaccurate reporting of recipient facility information.
  • Important differences among the 3 PRTRs that create gaps across the region – e.g.:
  • Different disposal terminology and definitions
  • Differing reporting requirements for sectors and pollutants – e.g.: oil and gas extraction, sewage treatment; manganese, zinc and barium compounds; total phosphorous
  • Shared responsibility for implementing regulations and monitoring waste.

RECOMMENDATIONS

TOP/COMMON SECTORS:

The analyses of data for transfers to disposal reveal similarities among the three countries in the top sectors, but also reveal gaps in data for these sectors across the region. While the scope and size of the top reporting sectors (e.g., iron and steel mills/ferroalloy manufacturing, oil and gas extraction, waste management, electric utilities), they are present in all three countries – therefore, we see that the gaps in data across the region for these sectors are in large part due to differences among Canadian, Mexican and US PRTR reporting requirements.

Recommendation: comparable reporting requirements for common industrial sectors/activities

TOP POLLUTANTS (by volume) / POLLUTANTS OF COMMON CONCERN:

Much emphasis in the report is on substances reported in largest proportions (e.g., zinc and manganese compounds, hydrogen sulfide, nitric acid/nitrate compounds, total phosphorus); but there are disparities in the substances subject to reporting in each country (and therefore, in the data available for analysis).

Of equal or greater importance than the volume of pollutants transferred to disposal is their potential for negatively affecting human health or the environment. Among the pollutants transferred to disposal, 210 are known for their potential to cause harm to human health or the environment—that is, they can affect human development or reproduction, are known or suspected carcinogens, or have the potential to persist in the environment and biomagnify within the food chain. But varying PRTR reporting requirements for these substances hinder our ability to fully understand the risks related to their disposal. A related issue that hinders our ability to understand the potential risk of pollutants is that, depending on the country, some pollutants are reported as groups (e.g., the chromium compounds group includes hexavalent chromium compounds, which are extremely toxic, with other, less toxic chromium compounds).

PRTRs offer the possibility of tracking pollutant releases and transfers, as well as contributing to raising awareness about known or emerging issues associated with them. For example, information has come to light about the negative impacts of per- and polyfluoroalkyl substances (PFAS), a group of synthetic chemicals manufactured and used in food packaging, firefighting foams, heat-, water- and stain-repellent products worldwide for more than 50 years. Certain PFAS, also known as "forever chemicals" because they can accumulate and remain in the human body for long periods of time, are associated with cancer, thyroid and liver problems, and birth defects. Recently, high levels of PFAS have been found in the sewage sludge-based biosolids applied to farmland in the United States and elsewhere. The UNECE's International PRTR Coordinating Group recommended that certain PFAS be included in PRTR pollutant lists and the US added 172 PFAS to the TRI for the 2020 reporting year.

Recommendation: ensure comparable reporting requirements across the region for common pollutants (prioritizing those of concern due to their potential negative impacts on human health/environment, including emerging contaminants)

INFORMATION ABOUT THE FINAL DESTINATION OF POLLUTANTS TRANSFERRED TO DISPOSAL (INCLUDING ACROSS BORDERS):

Example of difficulty of tracking waste metals from battery manufacturing (from p. 101)

The metals used to produce batteries, such as copper, lead, and cadmium, can be expensive and so battery manufacturers often recycle/reuse them. This can involve transferring waste lead and other metal compounds to a waste management facility, which might then transfer all or part of the waste to a secondary lead smelter for refining. But any portion of the metal waste that is contaminated (for example, lead waste contaminated with cadmium) cannot be used in new batteries and might be transferred to a different facility for stabilization or reuse (e.g., in cement or building materials). Some or all the metal-laden furnace dust might also be sent to this second facility or transferred to a landfill for disposal.

Fig. 23: the data reveal that source facilities often indicate inaccurate, or no, locational information for the facilities receiving the waste, or provide generic descriptions in lieu of an official name (e.g., "landfill," "agricultural land," "injection well No. 2," "transfer station," "garbage"). Among the clearly identified recipients of transfers to disposal are waste management facilities, cement plants, smelters, landfills, underground injection wells, wastewater treatment plants, chemical manufacturers, farms and agricultural land, etc. However, website information for some of these recipients raises questions about their suitability relative to the wastes transferred to them (e.g., certain landfills specify that they are not designed to receive hazardous waste, yet the data show that they receive pollutants—often in large quantities—that can potentially pose risks, depending on the form they take (if they are stabilized, or inert).

Example of cross-border transfers of spent lead-acid batteries in North America

A CEC report from 2013, Hazardous Trade? An Examination of US-generated Spent Lead-acid Battery Exports and Secondary Lead Recycling in Canada, Mexico, and the United States, was developed to address concerns about a surge in US exports of spent lead-acid batteries, primarily to Mexico, resulting from the strengthening of US ambient air and emissions standards for lead in 2008 and 2012, respectively. These increased exports resulted in a higher risk of exposure to lead by workers and the people living near certain recycling operations in Mexico. The report revealed that more than 50% of the secondary lead smelters in that country had not reported their lead emissions to the RETC, partly due to a lack of clarity about whether some of these smelters could be classified as recycling facilities and thus not be subject to RETC reporting requirements for air emissions. The report's recommendations led to the establishment of clear emission standards for secondary lead smelters, as well as the reporting of their lead emissions to Mexico's RETC. These standards cover not only air emissions from active smelters, but also the risks of contamination arising from abandoned operations. One such facility is the former Metales y Derivados lead smelter and battery recycling maquiladora in Tijuana, Baja California, described in the CEC's factual record from 2002. This abandoned site was a hazard to the nearby community because it was contaminated with approximately 6,000 tons of lead slag, sulfuric acid, antimony, arsenic, and cadmium that could easily spread due to exposure to the wind and rain. Public scrutiny resulted in the site being remediated in 2008.

Recommendation: ensure complete and accurate reporting of the final destinations of pollutants – including those sent across borders – and ensure that adequate details are provided about their disposal (e.g., remove the option to report "other disposal")

FACILITIES REPORTING ON POLLUTION PREVENTION PRACTICES (REF: Section 2.5):

The ability to access accurate and complete data relative to the management of pollutants of common concern by North American industrial sectors can support policies and actions to prevent not only their inadvertent release because of improper disposal, but also their use in the first place. The report provides examples of pollution prevention (P2) or sustainability practices from NA reporting companies/facilities related to the top sectors and pollutants in the report – e.g.:

• • 80% of these companies have replaced raw materials and/or integrated recycled raw materials into their processes;
  • 76% have made process changes;
  • 64% have optimized their logistical processes;
  • 64% have received certifications related to quality management systems; and
  • 32% have participated in the creation of green value chains.

It also shows that the PRTR programs have incorporated into their reporting requirements information on facilities' P2 activities and, importantly, information about the challenges they face in this respect.

Recommendation: ensure more reporting by facilities of their P2 and related activities and challenges; and support the sharing of this information among sectors and across NA

SHARED RESPONSIBILITY FOR INDUSTRIAL/HAZARDOUS WASTE TRACKING AND DISPOSAL

Canada: The federal government regulates the transboundary movements of hazardous waste and recyclable hazardous materials under the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (EIHWHRMR). Provincial, territorial and municipal authorities are responsible for regulating the treatment, storage, and disposal of hazardous waste within their jurisdictions. Although the federal government does put forward regulations and standards, the regulation of hazardous waste management activities is the responsibility of the provincial, territorial, and municipal authorities. Accordingly, regulations may vary widely from one jurisdiction to another.

Mexico: Surface impoundments are not regarded as a final waste disposal method and a distinction is made between "controlled confinement" and "landfills." The regulation of confinement sites for hazardous waste control and neutralization is stricter than the regulation of landfills intended for residential and special management waste. The regulation and control of the disposal of hazardous waste is the responsibility of the General Directorate for Comprehensive Management of Hazardous Materials and Activities (Dirección General de Gestión Integral de Materiales y Actividades Riesgosas—DGGIMAR), as disposal is considered one of the stages or activities in the comprehensive management of hazardous waste. Thus, hazardous waste regulation is parallel with and independent of the regulation of PRTR listed substances. Discrepancies found in the RETC may reflect the fact that hazardous waste management and disposal are sometimes contracted to authorized third parties. In such cases, the waste generator's responsibility is transferred to said third parties, who are then responsible for requesting the necessary authorizations from DGGIMAR to carry out their waste management operations.

United States: The SDWA sets a framework for the Underground Injection Control (UIC) program, with regulations for the construction, operation, permitting and closure of injection wells (which are regulated under RCRA, as mentioned earlier) to ensure that injected wastes do not endanger underground sources of drinking water (USDWs). The EPA is charged with developing UIC requirements to protect USDWs from potential pollution due to underground injection activities; however, it has approved primacy status (i.e., authority) to thirty-one states and three territories relative to Class I, II, III, IV and V underground injection wells. The principal means at the disposal of the EPA and the competent state authorities for enforcing UIC Program compliance is to inspect permitting conditions on injection sites (EPA 2016c).

Recommendation: Strengthen the coordination between agencies to ensure that transfers to disposal are adequately tracked and managed.

Examples of issues associated with industrial disposal practices (section 2.3.2)

1. Underground injection

Oil industry waste disposal wells in West Virginia

In 2016, the Natural Resources Defense Council (NRDC) conducted an analysis of class II disposal wells in West Virginia, which revealed a series of ongoing problems with respect to compliance with environmental regulations. Class II wells are used by the oil and gas industry to improve oil recovery in deep formations or to dispose of wastewater generated by exploration and production activities. Among the problems encountered were ongoing injection operations with expired permits; failure to conduct mechanical integrity testing as often as required; and over half of non-operational wells not capped in accordance with regulatory requirements, in some cases even after ten years. That year, the EPA compiled information based on various characterization studies of wastewater generated by oil and gas operations. Among the components detected in the wastewater were total dissolved solids, total suspended solids, chloride, oil and grease, benzene, toluene, ethylbenzene, xylene, heavy metals such as barium, strontium and magnesium, and radioactive materials. Among the six principal routes identified by the EPA for the migration of these wastewater components into potable water sources were well casing pipe failures and migration from improperly capped abandoned wells.

2. Landfills or surface impoundments

a) Coal ash ponds in the United States

Coal combustion residuals (CCRs), or coal ash, are byproducts of the combustion of coal by electric utilities. Coal ash contains contaminants like mercury, cadmium and arsenic associated with cancer and various other serious health effects. In 2012, approximately 110 million tons of coal ash were generated, 40% of which was beneficially used (e.g., in cement), with the remaining 60% disposed in surface impoundments and landfills (commonly known as coal ash ponds) averaging 120 acres and 40 feet in depth. In 2019, an environmental nongovernmental organization (NGO) collaborated in the compilation and analysis of the groundwater monitoring data published by over 200 coal-fired power plants or off-site coal ash disposal sites in compliance with the EPA's 2015 Coal Ash Disposal Rule, which established groundwater monitoring requirements for coal ash landfills and required electric utilities to make the data public as of 2018. The data cover over 550 different coal ash ponds and landfills that are monitored by over 4,000 groundwater monitoring wells, representing around 75% of the country's coal-fired power stations. A comparison between these groundwater monitoring data and the health-based standards and government advisories revealed the existence of contaminated water beneath most of the plants in the study. Over 50% of the sites had dangerous levels of arsenic and lithium, which are known for their potential to cause neurological damage, and ten sites had concentrations of these and other pollutants (e.g., cadmium, cobalt, selenium, molybdenum), of 100 to 500 times the recognized safe levels. One, the Big Sandy Power Plant in Kentucky, was included in the EPA's list of high hazard potential ratings because its groundwater contains dangerous levels of arsenic, radium, cobalt, sulfates, beryllium and lithium. In January 2022, EPA announced it will enforce the 2015 Coal Ash Disposal Rule to address the more than 500 unlined coal-ash ponds in the United States.

b) Tailings management areas in Alberta, Canada

Canadian oil and gas extraction facilities, as well as other mining facilities, may dispose of their tailings in tailings management areas, either on- or off-site. In 2017, two NGOs and a Canadian citizen filed the Alberta Tailings Ponds (II) complaint via the CEC's SEM mechanism – affirming that the Government of Canada was failing to enforce the pollution prevention provisions of the Fisheries Act, in relation to the alleged release of deleterious substances in surface waters frequented by fish or via the groundwater and soil surrounding these waters in northeastern Alberta. The pollutant substances are contained in oil sands process-affected water (OSPW), a by-product of the tailings generated by mining operations. OSPW contains a toxic mix of naphthenic acids, heavy metals and other chemicals, the result of the process of separating oil sands from other materials during open-pit mining operations. Tailings ponds are designed for the temporary storage of OSPW and enable the tamping down of the fine particulates in the tailings (by submerging them under water). However, due to the challenges of maintaining the structural integrity of the walls of tailings ponds, OSPW slowly filters through these containment structures. In its response to the submission, the Canadian government acknowledged that no applicable federal regulations exist regarding the depositing of substances in oil sands tailings ponds. However, regulations on oil sands effluents are currently being drafted under the Fisheries Act to prohibit the depositing of OSPW, including from tailings ponds, in waters frequented by fish/ where OSPW might enter such waters.

c) Breach of a mine tailings dam in Sonora, Mexico

A spill at Grupo Mexico's Buenavista del Cobre mine in Sonora, Mexico, in 2014 was caused by a broken pipe in an acid copper tailings pond. An estimated 40,000 m³ of a metal-laden, highly acidic solution was released into the Las Tinajas stream, which flows into the Bacanuchi River and then the Sonora River. The spill's initial impacts extended 90 km downstream, raising concerns about effects on aquatic life, drinking water and the economies of seven communities.

3. Land application

a) Inadequate monitoring of substances contained in biosolids in the United States

A November 2018 report of the EPA's Office of the Inspector General identified deficiencies in the agency's controls on the use of biosolids in land application in relation to the protection of human health and the environment. While the EPA constantly monitored biosolids to detect the presence of nine regulated pollutants (heavy metals), it lacked the necessary personnel, data, and risk assessment tools to evaluate the safety of 352 pollutants found in biosolids (including pharmaceutical chemicals, steroids, and flame retardants), identified in studies conducted between 1989 and 2015. Sixty-one (61) of these pollutants are designated as highly hazardous, hazardous or priority substances by other programs. Under the Clean Water Act, the EPA is required to review its regulations on biosolids at least once every two years to identify additional toxic pollutants and, as required, develop related regulations.

Lack of treatment of sludges prior to disposal in Mexico

Mexican authorities have recognized that, at times, guidelines for the design and application of sludges are not respected and that these materials are applied to agricultural soils without having received adequate treatment (Conagua 2015). Various studies have shown that wastewater treatment plants dispose of untreated sludges in open air locations, or on land which has not been prepared for this purpose. According to the findings of a 2016 audit of a treatment plant in Ensenada, Baja California, sludges were simply mixed with other materials and disposed of in situ, on the grounds of the plant.

Other:

Surface impoundments – these are like a tailings pond and are used by mines, power plants (e.g. coal ash ponds). Issues are leakage, breakage – examples of re-mobilization of pollutants:

• Hurricane Katrina, Canada's Mount Polly (copper mine tailings dam), rupture of a tailings pond pipe at Buenavista del Cobre copper mine, Mexico
• if you know what's there, you can have an informed response; knowing the types and amounts of substances is key for disaster response.

Abandoned/unused disposal sites have been classified as superfund sites. Storage operations end up being poorly managed and risk being a ticking time bomb – but tend to get little attention. Re: March 27 EPA Superfund notice: the newly added sites are of concern because they can impact drinking water, etc. – e.g.:

• https://dnrec.alpha.delaware.gov/waste-hazardous/remediation/east-basin-road/: the suspected sources are probably a federal army base and airport
• https://www.muskogeephoenix.com/news/fansteel-files-lawsuit-to-cover-costs-of-remediation/article_0c6f1cae-0fad-5f86-aadc-889f8306e64c.html: leak substances were in storage ponds on site
• https://www.nola.com/news/environment/baton-rouges-capitol-lakes-being-investigated-again-as-possible-superfund-site/article_97d5b094-7f99-11ec-bda6-830129f9f566.html: source of contaminants (including PCBs) might be leakage from Westinghouse Electric transformer repair facility's underground storage tank.

GAPS REVEALED BY THIS REPORT

Gaps in pollutants and sectors subject to PRTR reporting:

• Canada total phosphorous = 89% of all OSD, but not subject to reporting in US and Mexico
• Barium – 87% of US reported, but not subject to reporting in Canada and Mexico
• Other top pollutants, including metals, can be ranked by their toxicity equivalency potential (TEP), and prioritized because of the risk of their being released to the air or water.
• The key sectors shown in the OSD analysis are common to the three countries (e.g. iron and steel mills, oil and gas, mining, waste management, sewage treatment plants); therefore, we could prioritize sectors and activities and target top pollutants reported, for P2 policies and actions

Gaps in reporting in disposal practices: Mexico has data for three of the six disposal categories (none for underground injection, land application, and key differences in definition of "landfill")

Gaps in coordination for tracking/management of industrial waste: agencies sharing responsibilities and splitting up data.

Gaps in information about pollutants crossing national borders: need more complete information, as well as comparable reporting requirements, to ensure tracking and management of pollutants that cross borders.

WHY IS THIS REPORT IMPORTANT?

It explains risks related to sending pollutants off-site for disposal, and of having gaps in information:

• Example of PFAS (forever chemicals) contained in biosolids applied to land, which is a common practice everywhere – with the reporting showing a 40% increase over the past 5 years – possibly affecting our food, wildlife, ecosystem
• Risks of disposal in or on land, including underground injection, include contamination of groundwater affecting people who rely on wells for their drinking water and for watering crops
• Risks related to gaps in information – e.g., not knowing the types or quantities of pollutants in disposal sites that might get re-mobilized in an increasing context of extreme events, such as floods.

The report presents information that can be used to improve the tracking and management of industrial waste (including avoiding the generation of waste in the first place):

• The data analyses highlight some of the top pollutants generated by top sectors – many of which are common to the 3 countries. The information suggests where reporting requirements could be strengthened to ensure comparable data, and that the data could be used to prioritize the development of policies and actions for some of these common sectors and pollutants.
• It also highlights some issues relating to the shared responsibility for waste tracking and disposal that constrain our understanding of how waste is managed.
• The report presents alternatives to the generation and disposal of waste and shows that PRTRs can play a role by improving reporting requirements to have better info about facilities' pollution prevention efforts. the US PRTR is also asking facilities to report on their challenges, which creates opportunities for sharing information about best practices for reducing inputs and generating waste that needs to be managed.